G.R. No. 128384 June 29, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REYNALDO SAHOR BAÑAGO, accused-appellant.

FACTS

Accused-appellant Reynaldo Bañago was charged with the rape of thirteen-year-old Dolores Jaurigue on October 15, 1993, in Marilao, Bulacan. The prosecution evidence established that the victim was alone in a company bodega where her sister resided. She was awakened by Bañago, who poked a gun at her, slapped her when she tried to shout, and proceeded to have carnal knowledge of her. Her sister, Dorotea, later saw Bañago leaving the bodega. Fearful of Bañago’s threats, Dolores delayed reporting the incident. She eventually disclosed it to her aunt in March 1994 and to her mother, leading to a medico-legal examination which confirmed her non-virgin state, though it found no signs of recent violence. A criminal complaint was filed in July 1994.
The defense presented an alibi. Bañago, a welder, claimed he was in Quezon City with a co-worker, Delfin Castillo, to collect his salary on the afternoon and evening of the incident and did not go to the bodega. The trial court rejected the defense, convicted Bañago of rape, sentenced him to reclusion perpetua, and ordered him to pay P50,000.00 in moral damages. Bañago appealed, challenging the victim’s credibility and the delay in filing the complaint.

ISSUE

Whether the trial court erred in convicting accused-appellant of rape based on the victim’s testimony and in awarding moral damages.

RULING

The Supreme Court affirmed the conviction but modified the damages. The Court upheld the trial court’s assessment of the victim’s credibility, emphasizing that factual findings of the trial court are generally binding, especially on witness credibility. The victim’s categorical and straightforward testimony on how the rape was committed was given full weight. The delay in reporting was sufficiently explained by the accused’s threats and the natural shame and fear experienced by a young victim, which does not undermine credibility but makes it more understandable. The medico-legal report, while noting no signs of recent violence, corroborated her non-virgin state, consistent with the five-month gap before the examination.
The legal logic is clear: a rape victim’s testimony, if credible, is sufficient to sustain a conviction. The defense of alibi cannot prevail over the positive identification by the victim. The Court also affirmed the award of P50,000.00 as moral damages, which may be awarded in rape cases without need of specific proof. However, the Court modified the award by additionally ordering accused-appellant to pay P75,000.00 as civil indemnity, which is mandatory upon a finding of rape and distinct from moral damages. The decision was affirmed with modification.